JCC Denies Follow-Up Visit After Normal Knee Findings

In Lakecha Grant v. JetBlue / Sedgwick CMS, OJCC Case No. 23-003879MJR, the claimant sought authorization for a follow-up appointment with one-time-change orthopedist Dr. Richard Strain after a January 7, 2023 left-knee accident involving luggage and a baggage cart. The employer and carrier had accepted the accident as compensable, but defended the petition on the ground that the knee contusion had resolved and any remaining complaints were not supported by objective findings.

Judge Michael J. Ring denied the follow-up request after crediting Dr. Strain’s records and deposition testimony over the claimant’s position. The order emphasizes that compensability and entitlement to ongoing benefits are separate issues, and it found the only medical opinion in evidence showed a normal left knee, no objective evidence of continuing injury, MMI as of February 26, 2024, and no medical necessity for additional treatment tied to the industrial accident.

For carriers and employers, the ruling is a useful reminder that accepting an injury does not lock in perpetual care. When the authorized medical evidence shows the condition has healed and the claimant cannot prove continuing treatment is medically necessary, a later follow-up request can still be denied even in an accepted accident case.

Source: Compensation Order